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Home > Blog > Blog > Long Term Disability > Fourth Circuit Affirms United Mutual of Omaha’s Denial of Long-Term Disability Benefits Based on Insufficient Information

Fourth Circuit Affirms United Mutual of Omaha’s Denial of Long-Term Disability Benefits Based on Insufficient Information

In Shaw v. United Mutual of Omaha Life Insurance Company of America, No. 21-1818, 2022 WL 3369525 (4th Cir. Aug. 16, 2022), Plaintiff-Appellant Paramount Shaw appealed from the district court’s order granting United Mutual of Omaha Life Insurance Company’s motion for judgment on the pleadings in his lawsuit seeking long-term disability benefits under ERISA. As explained by the court, United denied Shaw’s claim for disability benefits due to his alleged failure to provide documents that United requested. The policy under which United provides benefits states that failure to provide information needed to prove loss could invalidate or reduce a claim and that supporting information may be required. Shaw did not provide United with the information and did not otherwise engage United in a discussion about why he objected to providing the information. Instead, Shaw asserts that the information United requested was irrelevant and that it had sufficient information to pay his benefits.

The court found that the scope of United’s request is irrelevant since Shaw did not object to the requests nor did he assert any basis for his failure to respond. Because Shaw ignored the repeated requests, the court found that United’s determination that it had insufficient records to determine disability was reasonable. The court also found that there was no evidence that United’s financial conflict of interest affected its interpretation of the plan.

The court affirmed the judgment of the district court.

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